2022 (6) TMI 1479

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....ellant ORDER We have heard learned standing Counsel for the appellant/revenue. There is a delay of 625 days in filing the appeal. We are not fully satisfied with the reasons given therein. Since we are inclined to take up the appeal for consideration, we exercise discretion and condone the delay in filing the appeal. Accordingly the delay in filing the appeal is condoned. In view of the above....

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.... proceedings and even penalty notice was duly received on behalf of the deceased assessee along with assessment order without objecting the same and the A/R representing the assessee duly co-operated with the penalty proceedings before the AO ? b) Whether on the facts and circumstances of the case and in law, the Ld. I.T.A.T. erred I law to appreciate the difference between wrong penalty notice ....